The Portfolio Management Association of Canada (“PMAC”), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on the Canadian Securities Administrators’ (“CSA”) Notice and Request for Comment – Proposed National Instrument 93-101 – Derivatives: Business Conduct (“NI 93-101”) and Proposed Companion Policy 93-101CP – Derivatives: Business Conduct (the “Consultation”). Capitalized terms used in this letter but not defined here have the same meaning given to them in the Consultation.
PMAC represents investment management firms registered to do business in Canada as portfolio managers. PMAC members encompass both large and small firms managing total assets in excess of $1.5 trillion for institutional and private client portfolios.
PMAC advocates for the highest standard of unbiased portfolio management in the interest of the investors served by our members. PMAC consistently supports measures that we feel elevate standards in the industry, enhance transparency, improve investor protection and benefit the Canadian capital markets as a whole. We support the CSA’s aim to establish a robust investor protection regime that meets the International Organization of Securities Commissions’ (“IOSCO”) standards with respect to over-the-counter (“OTC”) derivatives.